For Indian Exporters Entering the EU Market
Exporter: _____________________________________________
Product / HS Code: _____________________________________________
EU Destination(s): _____________________________________________
Date: _____________________________________________
This checklist consolidates all EU compliance requirements that an Indian exporter must address before the first shipment to an EU market. It is structured by compliance domain and should be completed in conjunction with the relevant detailed guides in this document library. Items marked with an asterisk (*) are legal requirements without which the goods cannot legally be placed on the EU market.
SECTION 1 — TARIFF AND CUSTOMS COMPLIANCE
SECTION 2 — PRODUCT SAFETY AND CE MARKING
SECTION 3 — FOOD SAFETY AND AGRICULTURAL COMPLIANCE
Complete this section only for food, agricultural, and feed products.
SECTION 4 — CHEMICALS, REACH AND RoHS
Complete this section for chemicals, mixtures, articles, and electrical/electronic equipment.
SECTION 5 — TIMBER, DEFORESTATION, AND SUSTAINABILITY
Complete for wooden products, furniture, paper, palm oil, soya, cattle, cocoa, coffee, and rubber.
SECTION 6 — DATA PROTECTION AND DIGITAL COMPLIANCE
SECTION 7 — LABELLING, PACKAGING, AND MARKING
SECTION 8 — SANCTIONS AND EXPORT CONTROL
SECTION 9 — ENVIRONMENTAL AND ESG COMPLIANCE
COMPLIANCE READINESS SUMMARY
* Items marked with an asterisk are legal requirements — goods cannot be legally placed on the EU market without these. All asterisked items must be Complete before first shipment.
Doc 75 — EU Compliance Preparation Checklist for Indian Exporters — Neutral Template
| Item | Done | Notes / Reference |
|---|---|---|
| * 8-digit EU Combined Nomenclature (CN) code confirmed on EU TARIC — MFN duty rate and all applicable measures verified. | [ ] | |
| GSP preferential rate confirmed on EU Access2Markets — product not graduated for India. | [ ] | |
| * REX registration obtained from DGFT. REX Statement of Origin text included on export invoice template. | [ ] | |
| Rules of Origin analysis completed — product qualifies for GSP/FTA preference (Doc 49 checklist completed). | [ ] | |
| Anti-dumping duty (ADD) status checked — no ADD applies to this product from India on the applicable CN code. | [ ] | |
| Safeguard TRQ status checked (for steel, aluminium, and other TRQ-covered products) — TRQ headroom confirmed. | [ ] | |
| CBAM applicability checked (steel, aluminium, cement, fertilisers, hydrogen) — carbon data collection initiated if applicable. | [ ] | |
| * EORI number obtained by EU importer/buyer — confirmed before first shipment. | [ ] | |
| Incoterms agreed with EU buyer — DDP avoided unless EU EORI held by Indian seller. | [ ] | |
| EU customs value calculation method confirmed (CIF basis for EU customs duty). | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| * Applicable EU Directives and Regulations identified for this product (Machinery, LVD, EMC, RED, PPE, Toys, MDR, PED, etc.). | [ ] | |
| * Conformity assessment procedure identified — self-declaration or Notified Body involvement required. | [ ] | |
| * Applicable harmonised standards (EN standards) identified and product tested against them. | [ ] | |
| * Technical File compiled — includes: product description, design drawings, risk assessment, test reports, DoC. | [ ] | |
| * EU Declaration of Conformity (DoC) drawn up — signed by manufacturer or EU Authorised Representative. | [ ] | |
| * CE mark affixed to product or packaging — minimum 5mm height, legible and indelible. | [ ] | |
| Notified Body certificate obtained (where required for higher-risk products — Class II/III medical devices, certain PPE, pressure equipment, etc.). | [ ] | |
| * EU Responsible Person appointed under GPSR (Regulation (EU) 2023/988, from August 2024) for consumer goods from non-EU manufacturers. | [ ] | |
| Technical File retained for 10 years from date of last manufacture — storage location and custodian confirmed. | [ ] | |
| Market surveillance: Procedure established for responding to product safety alerts and market surveillance authority requests. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| * EU MRL compliance: Multi-residue pesticide screening by NABL/ISO 17025 accredited laboratory completed on the export lot. | [ ] | |
| * Aflatoxin testing (for groundnuts, spices, cereals, dried fruits) by accredited laboratory. | [ ] | |
| * Phytosanitary Certificate from Plant Quarantine Station (PQIMS application completed; inspection scheduled). | [ ] | |
| * Health/Veterinary Certificate from AQCS/FSSAI (for products of animal origin — seafood, meat, dairy). | [ ] | |
| TRACES NT pre-notification filed (for regulated plant and animal products) — at least 1 working day before BIP arrival. | [ ] | |
| * EU food labelling compliance (Regulation (EU) 1169/2011): All 14 allergens declared; net quantity; best before; storage conditions; EU food business operator details; nutrition declaration. Label in language of destination member state. | [ ] | |
| FSSAI export certificate obtained where required by destination country. | [ ] | |
| Enhanced border check status verified (EU 2019/1793 list) — if applicable, pre-notification and test report filed. | [ ] | |
| Organic certification by EU-recognised Indian certifying body (if marketing as organic). | [ ] | |
| GI certificate obtained and attached to shipment documentation (for GI-protected products). | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| SVHC Candidate List checked — product does not contain SVHC above 0.1% w/w (or declaration prepared where it does). | [ ] | |
| REACH Annex XVII restrictions checked — no restricted substance above permitted limit in the product. | [ ] | |
| REACH Annex XIV — no authorisation-listed substance without authorisation. | [ ] | |
| REACH-compliant Safety Data Sheet (SDS) prepared per Regulation (EU) 2020/878 — in language of destination member state. | [ ] | |
| * Only Representative (OR) appointed in EU if substance registration volumes require (≥1 tonne/year imported into EU). | [ ] | |
| * RoHS compliance: For EEE — all 10 restricted substances confirmed below MCV. RoHS Declaration of Conformity prepared. | [ ] | |
| Nickel release test: For jewellery and skin-contact articles — nickel release confirmed <0.5 μg/cm²/week. | [ ] | |
| Chromium VI: For leather goods — Cr(VI) content confirmed <3 mg/kg. | [ ] | |
| Azo dye test: For textiles and leather — carcinogenic aromatic amines confirmed absent above limits. | [ ] | |
| Food contact safety: For ceramics, plastics, paper in food contact — migration tests for lead, cadmium, and applicable substances completed. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| * EUTR compliance: Timber legality documentation prepared — species identification, country of harvest, forest management certificate or equivalent. | [ ] | |
| EUDR (EU Deforestation Regulation): Assessed whether product falls within EUDR scope. If yes — geo-referenced sourcing data collected and due diligence statement prepared. | [ ] | |
| CITES: For rosewood (Dalbergia spp.), rattan, and other CITES-listed species — CITES export permit from India obtained. | [ ] | |
| FSC / PEFC certification: If EU buyer requires sustainable forest management certification — certification obtained or supplier confirmed as certified. | [ ] | |
| ISPM-15: All wood packaging (pallets, crates, dunnage) carries valid IPPC mark — treatment certificate available. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| GDPR compliance: If any EU personal data is processed in connection with the transaction (buyer contacts, employee data of EU residents) — Data Processing Agreement (DPA, Doc 11) signed with EU counterparty. | [ ] | |
| Standard Contractual Clauses (SCCs): If EU personal data is transferred to India — SCCs incorporated in DPA. | [ ] | |
| Privacy notice: If collecting EU individual data (e.g. end customer contacts) — GDPR-compliant privacy notice in place. | [ ] | |
| EU AI Act: If supplying AI systems to EU buyers — risk category assessed and applicable compliance measures initiated. | [ ] | |
| NIS2: If supplying IT services to EU critical sector entities — NIS2-aligned security controls documented. | [ ] | |
| DORA: If supplying IT services to EU financial entities — DORA exposure assessed and contractual obligations reviewed. | [ ] | |
| EU Battery Regulation: If supplying batteries — carbon footprint declaration and Digital Battery Passport timeline assessed. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| * Country of origin marking: "Made in India" (or equivalent in destination language) on product and outer packaging. | [ ] | |
| * Product labels in the official language(s) of the EU destination member state. | [ ] | |
| * Textile labelling: EU fibre composition and care instructions in destination language — correct EU fibre names used. | [ ] | |
| Weights and measures: Net quantity in metric units (kg, g, ml, l) — dual labelling (metric + imperial) not acceptable in EU. | [ ] | |
| Dangerous goods labelling: For hazardous goods — GHS/CLP classification labels in destination language, UN number and hazard class on outer packaging. | [ ] | |
| * Battery marking: For products containing batteries — crossed-out wheelie bin symbol, chemical content marking. | [ ] | |
| WEEE marking: For EEE — crossed-out wheelie bin symbol indicating separate collection obligation. | [ ] | |
| Energy label: For products covered by EU Energy Labelling Regulation — correct EU energy label in destination language. | [ ] | |
| ErP (Ecodesign): For products covered by EU Ecodesign Regulation — product meets minimum energy efficiency requirements. | [ ] | |
| Barcode / EAN: EU buyer's required barcode format correctly applied and scannable. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| * Sanctions screening: EU buyer and all known beneficial owners screened against EU, UK, UN, and US OFAC sanctions lists. | [ ] | |
| * SCOMET: Product confirmed as not on SCOMET control list, or SCOMET licence obtained. | [ ] | |
| * EU dual-use: If supplying to an EU buyer who will re-export — EU dual-use Regulation (EU) 2021/821 applicability assessed. | [ ] | |
| End-user certificate: For dual-use or sensitive goods — EUC obtained from EU buyer. | [ ] | |
| Transaction monitoring: Ongoing screening process established for changes in buyer sanctions status during the commercial relationship. | [ ] |
| Item | Done | Notes / Reference |
|---|---|---|
| EU Corporate Sustainability Due Diligence Directive (CSDDD): Assess whether EU buyer is subject to CSDDD supply chain due diligence obligations — prepare to respond to sustainability questionnaires. | [ ] | |
| CBAM (carbon pricing): For CBAM-covered goods — embedded emissions data available to EU buyer for quarterly CBAM reporting. | [ ] | |
| Packaging waste (EU Packaging Regulation): If supplying packaged goods — packaging design assessed for recyclability and recycled content requirements. | [ ] | |
| Extended Producer Responsibility (EPR): EU buyer's EPR obligations for packaging, WEEE, and batteries understood — data on product weight and composition available for EPR reporting. | [ ] | |
| EU Taxonomy: If supplying green energy or clean technology goods — assess whether the activity qualifies as EU Taxonomy-aligned (relevant for EU buyer's ESG reporting). | [ ] |
| Section | Status | Critical Actions Outstanding |
|---|---|---|
| 1 — Tariff & Customs | Complete / Partial / N/A | |
| 2 — Product Safety / CE | Complete / Partial / N/A | |
| 3 — Food Safety / Agri | Complete / Partial / N/A | |
| 4 — REACH / RoHS / Chemicals | Complete / Partial / N/A | |
| 5 — Timber / EUDR / CITES | Complete / Partial / N/A | |
| 6 — Data / Digital | Complete / Partial / N/A | |
| 7 — Labelling / Marking | Complete / Partial / N/A | |
| 8 — Sanctions / Export Control | Complete / Partial / N/A | |
| 9 — ESG / Environment | Complete / Partial / N/A |